Pursuant to Article 9 of Regulation (EU) 2019/2088
Presentation of financial products that have sustainable investments as their objective. Financial market participants shall publish the information referred to in Article 10(1) of Regulation (EU) 2019/2088.
Scope
Financial market participant: Course Corrected VC (“Course Corrected” or “CC.VC”).
Scope: This disclosure applies to all funds managed by Course Corrected VC that have sustainable investment as their objective in accordance with Article 9 of Regulation (EU) 2019/2088 (each “the Fund”, together “the Funds”). The Funds covered at the date of this disclosure are listed in the table below; the list is updated when a new Fund is established.
| Fund | Legal entity identifier | Vintage |
|---|---|---|
| Course Corrected VC Fund I (Course Corrected Fund I AB) | 559342-1893 | 2021 |
| Course Corrected VC Fund II (Course Corrected Fund II AB) | 559498-7595 | 2024 |
All Funds share the same sustainable investment objective, investment strategy, impact methodology, monitoring framework and engagement policies, and the information below applies equally to each Fund. Fund-specific data (principal adverse impact results, avoided emissions, portfolio composition) is reported separately for each Fund in its annual periodic disclosure (Annex V) and its statement on principal adverse impacts (Annex I).
An “Investment” is a company (public or private) that a Fund owns equity in.
1. Summary
Course Corrected is a climate impact venture capital investor supporting outstanding entrepreneurs with fast growing and scalable businesses that drive the transformation towards climate positive alternatives and carbon efficient solutions with the potential to become leaders in their respective industries.
The Funds invest in companies with technologies that have the potential to significantly reduce global greenhouse gas emissions, while avoiding doing harm to other sustainability objectives and complying with the Funds' Prohibited Sectors Exclusion Policy.
The Funds only invest in companies that can be determined as sustainable, climate positive and SFDR aligned. Each Fund has 100 % of its investments in sustainable investments with an environmental objective.
Progress towards the sustainability objective of the Funds (to reduce GHG emissions) is determined via impact assessments, including but not limited to life cycle assessments or avoided emission calculations, validated by the Climate Advisory Board.
As an active investor, Course Corrected helps investments mature on their sustainability journey, continuously improving their operations, governance, and reporting.
The Funds' requirements to Investments have been tailored to fit early-stage (mainly pre-seed, seed and A-round) ventures in their formative years (so called micro-enterprises and SMEs), which means that requirements for policies and controls will increase as the company progresses in maturity and size.
2. Sustainability risks
Course Corrected takes sustainability risks into account in its investment decision-making process. “Sustainability Risks” as defined in Article 2(22) of the Regulation: “an environmental, social or governance event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of an investment”.
As part of Course Corrected’s standard procedure, sustainability risk is integrated into the investment decision process. This is done by flagging important risks in the investment proposals, identified by research, and through review of each investment by Course Corrected’s Climate Advisory Board.
Each investment is reviewed accordingly, and Course Corrected may decide to make an investment even if risks have been identified. If this occurs, Course Corrected may implement mitigation strategies, which may include but are not limited to ESG mandates, reporting requirements, management follow-ups, third party expert reviews, and oversight committees.
3. No significant harm to the sustainable investment objective
The Funds are committed to ensuring that their investments do not cause significant harm (DNSH) to any environmental or social objective in the pursuit of the GHG emission reduction objective.
Prohibited Sectors Exclusion Policy. To be eligible as a potential investment, a company must comply with the Funds' Prohibited Sectors Exclusion Policy, which covers activities with significant negative environmental or social impacts, including the fossil fuel sector and controversial weapons. The policy is enforced through the due diligence process.
Qualitative DNSH assessment. Assurance of the DNSH principle is qualitatively assessed during the investment process. Course Corrected takes a holistic perspective, assessing positive and negative sustainability impacts, both actual and potential. Given that the Funds invest in companies at a very early stage, the scope for causing substantial negative impact is considered limited; requirements on policies and controls increase as companies mature.
Consideration of principal adverse impact (PAI) indicators. The assessment of an investment’s performance on the DNSH principle occurs in relation to its performance on the PAIs. Throughout the holding period of each investment, the Funds collect data on all mandatory PAI indicators and two additional indicators (water usage and recycling; lack of grievance/complaints handling mechanisms related to employee matters). Data is gathered at a minimum annually. If performance on these indicators worsens, the Funds engage with the Investment to identify the causes and implement a corrective action plan.
The Funds also monitor their investments for environmental controversies. If a controversy is found, the Funds engage with the company to take appropriate action.
Alignment with the OECD Guidelines for Multinational Enterprises and the UN Guiding Principles on Business and Human Rights. Due to the early-stage nature of current and potential investments, the Funds do not yet have a formal process for assessing investee alignment with the OECD Guidelines and the UN Guiding Principles. Investees are screened against the Prohibited Sectors Exclusion Policy and monitored through PAI indicators 10 and 11 (violations of, and lack of processes to monitor compliance with, the UN Global Compact principles and OECD Guidelines). Course Corrected is evaluating how a formal process could be integrated in the investment process and during the holding period.
A separate PAI statement (Annex I) is published annually for each Fund.
4. Sustainable investment objective
The sustainable investment objective of each Fund is to contribute to climate change mitigation through investing in companies with a potential to contribute towards greenhouse gas (GHG) emission reduction through their products and services. Through their investments, the Funds enable products and solutions to grow that are considered less carbon-intensive compared to existing alternatives.
The investments will have a net-positive impact on climate change through the mitigation or avoidance of GHG emissions. While Course Corrected recognizes that there are many investment opportunities in companies that may have strong return potential, Course Corrected focuses only on those whose impact directly compounds with company growth.
The sustainable investments are made in economic activities with an environmental objective that do not currently qualify as environmentally sustainable under the EU Taxonomy (Regulation (EU) 2020/852). The Funds do not commit to a minimum share of Taxonomy-aligned investments and do not invest in fossil gas or nuclear energy related activities.
5. Investment strategy
The Funds are stage agnostic with a primary focus on companies in the pre-seed, seed and Series A stages.
The Funds invest across four themes:
- Energy Systems: companies delivering lower-cost production, faster deployment, and smarter grid operations.
- Industrial Efficiency & Intelligence: where industrial transformation meets commercial urgency.
- Electrification: hardware that makes the next wave of electrification physically possible.
- Circular Systems & Resource-Smart Products: companies where scaling the business and scaling the impact are the same thing; when they win customers, emissions fall.
Course Corrected seeks to invest in companies that have the potential to be category leaders, with strong founders and management teams and highly scalable business models.
Impact strategy
Course Corrected places consistent emphasis on impact in each step of the investment process, from screening, impact measurement and analysis, due diligence, periodic reporting and follow-up post-investment. Critical and instrumental to this process is the Climate Advisory Board, consisting of leading climate researchers from the Stockholm Environment Institute and the Stockholm Resilience Centre.
Course Corrected’s initial assessment of each potential investment is formulated as a “climate hypothesis” and validated by the Climate Advisory Board, which assesses the climate impact potential and supports in identifying potential weaknesses and/or adverse effects. Potential investees provide an impact thesis and supporting documentation (for example a life cycle assessment). This information is further analyzed and included in the Investment Memorandum and considered by the Investment Committee as a fundamental part of its decision-making criteria.
Course Corrected meets with the Climate Advisory Board on a quarterly basis, where investment cases and investment management are discussed, and passes insight and knowledge from the Board on to the investments.
Good governance. The Funds assess that investee companies follow good governance practices with respect to sound management structures, employee relations, remuneration of staff and tax compliance, with requirements scaled to the early stage of the companies and increasing as they mature.
6. Proportion of investments
Each Fund has a minimum of 100 % of its investments (excluding cash and cash equivalents held for liquidity and deployment purposes) in sustainable investments with an environmental objective. These are sustainable investments in economic activities that do not qualify as environmentally sustainable under the EU Taxonomy. The Funds do not make investments with a social objective or investments classified as “not sustainable”.
7. Monitoring of sustainable investment objective
The Funds monitor the following sustainability indicator to measure the attainment of the sustainable investment objective:
| Sustainability indicator | Relation to the sustainable objective |
|---|---|
| Greenhouse gas emission avoidance (tonnes of CO2 equivalents) | An impact indicator that directly measures GHG emission reduction and, as such, contribution to climate change mitigation. It represents a comparison of emissions from baseline product(s) with emissions from the portfolio company’s product(s). |
The indicator is evaluated for each investment, where applicable, as part of the pre-investment process and during the holding period, and aggregated avoided emissions are reported annually for each Fund in its Annex V periodic disclosure. Based on an Investment’s performance on this indicator, the Fund may provide resources to support execution of the agreed progress plan (Sustainability Action Plan), to help the Investment deliver on the targets agreed in connection with the investment agreement.
Course Corrected monitors holistic KPIs of each investment, extending to both financial and impact metrics. At minimum, portfolio companies provide information quarterly. Data on the mandatory PAI indicators and the two additional indicators is collected and reviewed annually during the holding period. In addition to active advisory roles within the early-stage companies, Course Corrected strives to proactively contribute to its portfolio companies.
8. Methodologies
In the due diligence process, Course Corrected assesses the climate impact potential of each investment. The Climate Advisory Board, consisting of climate research experts, reviews the potential climate impact, including potential adverse effects and weaknesses of each investment.
Calculations are based on the best available scientific evidence and involve collaboration with the Funds' technical and climate advisors. Course Corrected recognizes that for some products little information exists about the baseline case, and assumptions and estimations have to be made. The analysis can therefore include estimated data and assumptions and can be both qualitative and quantitative, given the early-stage nature of the investments. Over time, this information gap is expected to reduce within the portfolios. Material adjustments to calculations and baselines, including corrections of previously reported figures, are outlined in the periodic reporting documents.
Avoided emissions are assessed by comparing the emissions of a baseline product or service with the emissions of the portfolio company’s product or service. Where possible, Course Corrected and the portfolio companies update both the baseline and the company data as more information becomes available, using more rigorous assessment methods as data allows.
PAI indicators are calculated in accordance with the formulas in Annex I of Commission Delegated Regulation (EU) 2022/1288. Emissions data is primarily based on activity-based data provided by the investee companies and relevant, recognized emission factors; where available, reported emissions data from the investee companies is used directly.
9. Data sources and processing
a. The data sources used to attain the sustainable investment objective
To develop impact assessments, the Funds and the companies work together, using data from public databases and other (private) databases, and (verifiable) data from the Investment’s own operations. The data is used to assess the Investment’s performance on avoided GHG emissions, the impact indicator used to measure achievement of the Funds' objective, climate change mitigation.
b. Measures taken to ensure data quality
The Funds and the Investments:
- only use high-quality databases;
- only use validated data from the Investment;
- follow relevant ISO and GHG Protocol standards for LCA development;
- obtain third party verification of LCAs when/if sufficiently mature.
Course Corrected supports the companies in the data collection process to increase the scope and quality of data over time.
c. How data is processed
Where possible, Course Corrected and the portfolio companies update both the baseline and the company data as more information becomes available, using more rigorous assessment methods as data allows. PAI data is collected from each Investment and aggregated at Fund level in accordance with the formulas in Annex I of Delegated Regulation (EU) 2022/1288.
d. The portion of data estimated
The Funds estimate GHG emissions, including avoided emissions, for all investments. As the Funds invest in early-stage companies, the scope and quality of data varies between companies and reporting periods; some data is estimated using activity data and emission factors where measured data is not yet available. The portion of data that is estimated is expected to decrease as the portfolio companies mature.
10. Limitations to methodologies and data
Course Corrected recognizes that there will always be a lag between the databases and operations in the real world, and projections into the future have uncertainty built in. For early-stage companies there is often a lack of public data on baseline products, and data coverage across a portfolio may vary from year to year; the results may therefore differ between reference periods. The methodology is deemed to adequately contribute to the defined sustainable objective targeted by the Funds. Course Corrected regularly reviews the methodologies and data used to assess the attainment of the sustainable investment objective to ensure the most up-to-date approach possible. When severe limitations are identified, actions will be taken immediately to overcome them.
11. Due diligence
Impact and ESG
- Climate change mitigation impact (“avoided emissions”) calculations and impact thesis from the company, formulated as a climate hypothesis and validated by the Climate Advisory Board.
- Screening against the Prohibited Sectors Exclusion Policy.
- ESG: assessed and compared to internal ESG commitments, including a qualitative DNSH assessment and a review of good governance practices.
Other due diligence
- Legal: standard industry procedures with external validation by industry advisors. Includes intellectual property review.
- Commercial: standard industry procedures with external validation by industry advisors.
- Technical: standard industry procedures with external validation by industry advisors, including technical experts within the Course Corrected network.
12. Engagement policies
The Funds may decide to make an investment even if sustainability risks have been identified. In such cases, the Funds may apply appropriate mitigation measures, including but not limited to offering training for the Investments to support their capacity to control, mitigate and/or reduce such adverse impacts.
Since the Funds' sustainable investment objective is closely linked to the business of each investment, Course Corrected focuses on supporting the growth and commercialization of the companies. For the majority of the investments, the Fund has a seat on the board, which enables it to work closely with the investment and ensure that sustainability impacts and risks are on the board agenda. Where the Fund does not have a board seat, Course Corrected acts as an advisor to the investment.
During the holding period, the Funds use the results of the due diligence process to ensure that sustainability impacts and risks are continuously evaluated and reported on, and risks mitigated as needed. The Investment is obliged to periodically report on the agreed set of sustainability KPIs identified in the due diligence phase. These KPIs are reviewed on a regular basis to ensure that the Investment measures, manages and reports on relevant sustainability impacts and risks. As an active investor Course Corrected helps investments mature on their sustainability journey, including helping them develop relevant policies, codes of conduct, grievance mechanisms and LCAs. Course Corrected has committed to ensuring that the companies continue to develop LCAs and assessments to identify avoided emissions.
In the event of ESG incidents, the Funds will always engage in dialogue with the Investment and ask them to mitigate their negative impact in dialogue with the affected stakeholders. For engagement activities conducted in response to an incident or due to insufficient adaptive capacity, investments will be given the opportunity and resources to improve.
The main objective of the Funds' engagement activities is to reduce principal adverse impacts of investments and enhance the positive impacts of the Investments' operations.
13. Attainment of the sustainable investment objective
The Funds are committed to having a positive impact in the fight against climate change, in alignment with the Paris Agreement. Course Corrected supports the goal of the Net Zero Asset Managers Initiative of net zero greenhouse gas emissions by 2050 or sooner, in line with global efforts to limit warming to 1.5°C.
Given that there is no relevant benchmark index for early-stage businesses, an index has not been designated as a reference benchmark for any Fund.
The attainment of the objective is reported annually for each Fund in its Annex V periodic disclosure, including aggregated avoided emissions for the reference period and, where available, comparison with previous periods.
14. Future regulation and regulatory amendments
In the event that the regulation is changed in the future in ways that affect the possibility for the Funds to operate in compliance with the amended directives, Course Corrected will, in order to remain compliant without changing the Funds' mission and focus to invest in climate mitigation and climate-positive early-stage software and hardware businesses, seek the possibility to reclassify under such regulation if deemed necessary and justified by the Funds' legal advisors and auditors. Any such decision will always be taken together with the main investors of the Funds.
This document was first approved on June 29, 2023 and updated in October 2026 to apply to all Article 9 funds managed by Course Corrected VC and to reflect the periodic disclosures for the reference period 1 January – 31 December 2025.